High-Net-Worth Individuals Look to Expand Their Investments

High-Net-Worth Individuals Look to Expand Their Investments

by | Mar 20, 2024 | Finance, 2024

High-Net-Worth Individuals Look to Expand Their Investments

Jack Brister s p 500

Jack Brister

Founder, International Wealth Tax Advisors

Jack Brister, Founder of International Wealth Tax Advisors, is a noted international tax expert, with over 25 years of experience. Jack specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset protection structures.

Jack is a frequent featured speaker at numerous international financial conferences and has been named a Citywealth Top 100 U.S. Wealth Advisor.

Contact IWTA

To schedule an introductory phone conference with IWTA  founder Jack Brister simply click here. Email IWTA at bloginquiries@iwtas.com Or call the IWTA New York City office at 212-256-1142

High-Net-Worth Individuals Look to Expand Their Investments

 

High-net-worth and ultra-high-net-worth individuals are increasingly going outside their primary wealth management relationships to invest in alternative investments, cryptocurrencies, and ESG, according to a survey by PWC. 

 

These non-traditional investments offer the possibility of portfolio diversification, a hedge against inflation and higher returns. Beyond pure financial gain, this shift reflects a growing desire among high-net-worth investors to align their wealth with their values through ESG investing.

 

The Impact of the Global Minimum Tax on Corporate Flows

The Impact of the Global Minimum Tax on Corporate Flows

by | Mar 12, 2024 | Taxes, 2024, Finance

The Impact of the Global Minimum Tax on Corporate Flows

Jack Brister s p 500

Jack Brister

Founder, International Wealth Tax Advisors

Jack Brister, Founder of International Wealth Tax Advisors, is a noted international tax expert, with over 25 years of experience. Jack specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset protection structures.

Jack is a frequent featured speaker at numerous international financial conferences and has been named a Citywealth Top 100 U.S. Wealth Advisor.

Contact IWTA

To schedule an introductory phone conference with IWTA  founder Jack Brister simply click here. Email IWTA at bloginquiries@iwtas.com Or call the IWTA New York City office at 212-256-1142

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The Impact of the Global Minimum Tax on Corporate Flows

Is this the end of shifting profits from high-tax to low-tax jurisdictions?

The landscape of international taxation is undergoing a seismic shift with the implementation of the Organization for Economic Co-operation and Development’s (OECD) Global Minimum Tax (GMT). First proposed in 2019 to address the transformative impact of digital products and services on the taxes of multinational enterprises (MNEs), over 140 countries signed the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) in 2021.

This groundbreaking agreement aims to establish a minimum effective tax rate of 15% for large multinationals and promises to reshape the flow of corporate activities and investments across borders. But what exactly does this mean for businesses and the global economy?

One Challenge, Two Pillars

Globalization, along with the advent of the digital economy, provided a catalyst for many MNEs to shift profits to countries with advantageous tax regimes, which resulted in the loss of USD 240 billion annually in lost tax revenue, according to the OECD. To combat these lost revenues due to mismatched tax systems, the following pillars were introduced:

Pillar One: Expands a country’s authority to tax profits from foreign companies with no physical location on their soil. This is expected to reallocate taxing rights on more than USD 125 billion of profit to market jurisdictions each year. 

Pillar Two: Also referred to as Global Anti-Base Erosion Rules (GloBE), Pillar Two establishes a global minimum tax of 15% for companies with revenues over Euro 750 million (approximately USD 808 million), which is expected to generate approximately USD 150 billion in additional global tax revenues annually.

So far, 37 countries have either introduced draft legislation or adopted final legislation, transposing Pillar Two’s model rules into their national laws and taking concrete steps to implement the agreement. An additional 13 jurisdictions are still working on the legal framework for implementation. 

While all  27 EU member states have agreed to adopt the GMT,  and many have introduced draft legislation or adopted final laws to implement the GloBE Rules, none have yet activated the top-up tax mechanism or other aspects of Pillar Two.

Shifting Corporate Flows and Top-Up Tax Rule

Companies may adjust their global structures to minimize tax liabilities, possibly impacting specific industries or regions, as firms pivot their foreign investments. Indeed, countries that offer tax credits or subsidies will likely be on the receiving end of  global corporate migration.

 Even established tax havens like Switzerland, Ireland and Bermuda are considering additional tax credits and subsidies in an attempt to retain corporate investments.  Among the incentives being considered are expanded child care, qualified refundable tax credits, research and development tax credits, as well as education, training and start-up subsidies.

In an effort to reduce incentives for profit shifting, Pillar Two contains an aspect referred to as the “top-up tax rule”, a mechanism that applies if an MNE’s effective tax rate in any particular jurisdiction falls below the 15% minimum. In such cases, the MNE’s home country can impose an additional tax (the “top-up tax”) to ensure the effective tax rate reaches at least 15%.

 

Bipartisan Conflict Delays U.S. Deployment

Currently, the United States has yet to officially join the 140+ countries that agreed to implement Pillar Two within the OECD Inclusive Framework. However, the U.S. Treasury Department actively participates in discussions and contributes to technical aspects of the implementation.

 

Though U.S. domestic tax regulations haven’t changed, American companies face potential impacts from the agreement. For example, U.S companies operating in Switzerland may need to pay a 15% tax in Switzerland, regardless of existing U.S. tax structures.

The consequences of this divergence are multi-faceted. U.S. government tax revenue could decrease as companies shift profits to compliant nations. The lack of U.S participation creates uncertainty and complexity for global businesses operating across different tax regimes.

Exactly how much is at stake for the United States? According to the Tax Foundation, Pillar Two would “reduce U.S. corporate tax revenues by $64.3 billion over ten years.” At the same time corporations will likely report more of their U.S. income, raising U.S. tax revenues by $99.3 billion. “On net, we estimate that foreign Pillar Two adoption increases U.S. corporate tax revenues by $34.9 billion over 10 years,” says the Tax Foundation.

Will GLoBE Reduce globalization?

Another possible scenario would be companies shifting their operations back to their home countries as tax rates begin to even out globally. Globalization offered companies opportunities to grow revenues and decrease costs, by shifting operations  to lower-tax nations. 

The intricacy of global supply chains was put under extreme strain during the pandemic, and pushed many firms to rethink their strategies. Combined with added taxes and penalties, firms may return to domestic operations.

Looking Ahead

There are many potential benefits to the GMT, as it levels the playing field across jurisdictions, provides an opportunity for greater transparency and should foster greater equality in economic growth. However, the GMT will be challenging to implement and administer for corporations, and could also introduce trade disputes and political tensions. 

While some countries offer refundable tax credits, the U.S. is seen as a disadvantage as it offers non-refundable tax credits that are not allowed under the agreement. As the U.S. determines its next steps, continued monitoring and evaluation of the tax’s impact on businesses and the global economy is essential.

Watch this space for breaking global tax news as it develops.

 

Redefining the 16th Amendment: The Impact of the Mandatory Repatriation Tax on Ultra High Net Worth Clients

Redefining the 16th Amendment: The Impact of the Mandatory Repatriation Tax on Ultra High Net Worth Clients

by | Sep 26, 2023 | Taxes, 2023, International, U.S.

Redefining the 16th Amendment: The Impact of the Mandatory Repatriation Tax on Ultra High Net Worth Clients

Jack Brister s p 500

Jack Brister

Founder, International Wealth Tax Advisors

Jack Brister, Founder of International Wealth Tax Advisors, is a noted international tax expert, with over 25 years of experience. Jack specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset protection structures.

Jack is a frequent featured speaker at numerous international financial conferences and has been named a Citywealth Top 100 U.S. Wealth Advisor.

Contact IWTA

To schedule an introductory phone conference with IWTA  founder Jack Brister simply click here. Email IWTA at bloginquiries@iwtas.com Or call the IWTA New York City office at 212-256-1142

Redefining the 16th Amendment: The Impact of the Mandatory Repatriation Tax on Ultra High Net Worth Clients

 

How has a relatively minor tax bill — $14,729 to be exact — turned into one of the most important tax cases for the United States? The matter at hand is whether the United States federal government can tax unrealized gains as income in Moore v. United States (Docket 22–800). 

 

What is the Mandatory Repatriation Tax?

In 2017, the Tax Cuts and Jobs Act (TCJA) was signed into law, introducing  the mandatory repatriation tax (MRT), or transition tax, on pre-2018 profits that companies and some U.S. shareholders kept in sheltered accounts abroad. Prior to the Act, U.S. corporations were generally taxed on worldwide income, but foreign income could be deferred indefinitely by retaining earnings through a foreign subsidiary. Through Tax Code Section 95, MRT taxes profits regardless if shareholders receive the income.

 

Will SCOTUS Reinterpret the 16th Amendment?

The Sixteenth Amendment of the United States declares:

“The Congress shall have power to lay and collect taxes on incomes, from whatever source derived, without apportionment among the several States, and without regard to any census or enumeration.”

 

The Amendment was ratified in 1913 and granted Congress the authority to institute a graduated income tax on the earnings of American workers and  paved the way for the modern income tax system as it is known today. Prior to ratification, the United States collected the majority of revenue from tariff and excise taxes. The 16th Amendment is credited to Senator Norris Brown of Nebraska, who first proposed the idea of a nationwide income tax.

 

There have been several Supreme Court cases regarding the Amendment, including a 1915 case where the Court declared income tax constitutional.

 

Taxing Unrealized Gains: Moore v United States

Will Moore v. United States become one of the most important cases in tax history? The case dates back to 2005 when Charles G. and Kathleen F. Moore invested $40,000 in a friend’s firm, KisanKraft, in return for 11% of common shares. KisanKraft, which supplied modern tools to small farmers in India, is more than 50% owned by U.S. persons and is considered a controlled foreign corporation (CFC).

 

Like many CFCs, KisanKraft has never distributed earnings to shareholders, instead reinvesting all earnings as additional shareholder investments and keeping the funds offshore. Prior to 2017, U.S. citizens would only pay taxes on CFC earnings that were distributed due to the provision in the U.S. tax code called “Subpart F” (26 U.S.C. § 951), which allowed for the taxation of certain types of a U.S. person’s CFC earnings when that U.S. person owned at least 10% of a CFC’s voting stock. U.S. shareholders meeting this ownership threshold could be taxed on their share of specific categories of undistributed CFC earnings, such as dividends, interest, and earnings invested in certain U.S. property. 

 

However, Subpart F did not permit the U.S. government to tax U.S. shareholders on the CFC’s active business income held offshore. In other words, income generated by the CFC’s own business activities was only subject to U.S. taxation when it was repatriated to the U.S. through dividends, loans or investments in U.S. property. This traditional tax system allowed U.S. shareholders to defer U.S. taxation on foreign earnings as long as those earnings remained offshore. 

 

But when then-President Donald Trump signed the Tax Cuts and Jobs Act into law, U.S. corporate taxation changed from a worldwide system, where corporations were generally taxed regardless of where their profits were derived, toward a territorial system, where corporations are generally taxed only on their domestic source profits. 

 

Subpart F was modified by the MRT, and classified earnings derived after1986 as taxable income in 2017, regardless of whether the CFC distributed earnings. After Jan. 1, 2018, a CFC’s income taxable under Subpart F includes current earnings. But the Moores challenged this ruling. 

 

From Farm Tools in India to SCOTUS

In 2018, the Moores learned that due to the MRT, their tax liability for the year 2017 increased by approximately $15,000, based on their pro rata share of KisanKraft’s retained earnings. The Moores paid the tax, but believing that this provision violated their constitutional rights, specifically the 16th Amendment, took the case to District Court.

 

The District Court ruled in favor of the government and denied the Moores’ cross-motion for summary judgment, determining that the MRT was a tax on income, and although it was retroactive, it did not violate the Fifth Amendment’s Due Process Clause. Following the upholding of the decision by the Appellate Court, the Moores filed a petition for a writ of certiorari on Feb. 21, 2023, which was granted by the Supreme Court on Jun. 26, 2023.

 

By agreeing to hear the case, the court faces a challenge that goes far beyond the Moores case and could have implications on the entire U.S. tax system.

 

The Future of Taxes for High Net-Worth Clients

At stake for the U.S. government is billions in revenue. According to the District Court documents, the government estimates the MRT will generate $340 billion in tax revenue for the United States, helping to offset other individual and corporate tax cuts, as well as broader international tax reform in the 2017 TCJA.

 

But is there more on the line for affluent investors as the Supreme Court interprets whether the 16th Amendment has a realization requirement for income? If the MRT is upheld, it could possibly introduce a variety of new wealth taxes on anything the government deems income. Yet, if the justices consider the tax unconstitutional, the current partnership and international tax treaties — which routinely tax unrealized income — are at stake.  

 

Pre-Hearing Controversy

While Moore v United States is expected to be heard “soon,” there is no shortage of controversy within the high court itself regarding the case. On September 8th, The Hill reported that Justice Samuel Alito refused to recuse himself from the case after sitting for two interviews with an attorney involved in the case. The interviews, appearing in the Wall Street Journal Opinions section, prompted Senate Judiciary Chairman Dick Durbin (D-Ill.) and others to call for Alito’s recusal in the Moore case. 

 

IWTA will continue to keep you abreast of further developments on the Moore v United States case, and advise on how the decisions affect you and your clients’ financial future.

 

 

IRS: Partial Penalty Relief Still Available for 2019 and 2020 Returns, But it Depends…

IRS: Partial Penalty Relief Still Available for 2019 and 2020 Returns, But it Depends…

by | Oct 12, 2022 | Taxes, 2022, Compliance, U.S.

IRS: Partial Penalty Relief Still Available for 2019 and 2020 Returns, But it Depends…

Jack Brister s p 500

Jack Brister

Founder, International Wealth Tax Advisors

Jack Brister, Founder of International Wealth Tax Advisors, is a noted international tax expert, with over 25 years of experience. Jack specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset protection structures.

Jack is a frequent featured speaker at numerous international financial conferences and has been named a Citywealth Top 100 U.S. Wealth Advisor.

Contact IWTA

To schedule an introductory phone conference with IWTA  founder Jack Brister simply click here. Email IWTA at bloginquiries@iwtas.com Or call the IWTA New York City office at 212-256-1142

IRS: Partial Penalty Relief Still Available for 2019 and 2020 Returns, But it Depends…

 

Amidst the upheaval of the COVID-19 pandemic, some U.S. taxpayers were unable to file their 2019 or 2020 income tax returns within the IRS’ filing deadlines The Internal Revenue Service, in a show of understanding, fully waived penalties for individual taxpayers and businesses who filed certain late returns by September 30, 2022. Although the deadline has recently passed  — and the IRS is not extending it — taxpayers who file late 2019 or 2020 returns may nonetheless be eligible for partial penalty relief, according to the IRS. According to the IRS, the agency will calculate failure to file penalties based on an October 1st start date, not the date that a taxpayer’s returns were originally due. This means that taxpayers who missed the September 30th should nonetheless file their delinquent returns as early as possible. 

IRS Extends Provisional Grace

On August 24, the IRS announced that it would provide automatic, broad-based penalty relief for taxpayers filing several different kinds of tax and information returns, including Form 1040, U.S. Individual Income Tax Return; Form 1041, U.S. Income Tax Return for Estates and Trusts; and Form 1120, U.S. Corporation Income Tax Return (Notice 2022-36).

The relief also applies to taxpayers filing certain international information returns, including

Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts; Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner (Under section 6048(b)).

The IRS’ relief exempts eligible taxpayers from paying a failure-to-file penalty, which is a 5 percent penalty applied monthly, up to 25 percent of the unpaid tax when a federal income tax return is filed late, according to the IRS.

Importantly, the relief did not apply to situations where a fraudulent return was filed, or where the penalties were part of an accepted offer in compromise, a closing agreement, or were finally determined by a court.

Since the relief is automatic, taxpayers simply had to file their late 2019 or 2020 income tax returns on or before September 30, 2022. Taxpayers who had already paid their penalties received those back in the form of refunds or credits.

Tax Industry Seeks Penalty Forgiveness Extensions

After the IRS made its announcement, some lawmakers and accounting industry stakeholders asked the IRS to extend its deadline.

A group of Republican lawmakers wrote the IRS and requested an extension until mid-to-late November, noting that the five week period between August 24 and September 30 might be insufficient for taxpayers who need to gather information and supporting documents.

The American Institute of CPAs (AICPA) asked the IRS to extend the deadline to December 31, 2022, due to concerns that the timeline would overburden practitioners and might be too short for taxpayers living abroad.

“Given the complex facts often associated with international information reporting and that many affected taxpayers live abroad, the September 30 deadline is unrealistic and will fail to prompt a critical mass of impacted taxpayers to avail themselves of the benefits of the Notice,” said the AICPA.

The AICPA followed up with another letter asking the IRS to extend penalty relief to several international forms, including Form 8288, U.S. Withholding Tax Return for Dispositions by Foreign Persons of U.S. Real Property Interests; Form 8938, Statement of Foreign Financial Assets; and FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)

Partial Penalty Relief Still Available

The IRS declined to extend the filing period or expand relief to the forms listed by the AICPA. In a statement, IRS Commissioner Chuck Rettig said the IRS understood the concerns of taxpayers and practitioners, but needed to keep the September 30 deadline so it can prepare for the upcoming 2023 tax filing season.

However, taxpayers who missed the September 30 deadline may still receive partial penalty relief for the returns listed in Notice 2022-36. In the same statement, the IRS explained that taxpayers who file for the first few months after September 30 will be eligible for partial relief.  

According to the IRS, failure to file penalties for eligible returns filed after the deadline will start accruing on October 1, 2022, not the return’s original due date. However, failure to pay penalties and interest will accrue based on the return’s original due date.

 

Post Sep 30, 2022 Options

Taxpayers who missed the September 30 filing deadline for returns covered by Notice 2022-36 should immediately engage the help of a trusted tax advisor to file their returns as quickly as possible and take advantage of the IRS’ partial penalty relief. For taxpayers whose returns are not listed in the IRS’ notice, options for penalty relief may be more limited; counsel from a tax professional will be necessary to determine the proper course of action. 

GRA drags 48 businesses to court …over tax evasion, failure to issue VAT invoices for goods, services

GRA drags 48 businesses to court …over tax evasion, failure to issue VAT invoices for goods, services

by | Oct 11, 2022 | 2022

Who needs to file fbar

About 48 businesses are currently undergoing prosecution for evading taxes and failing to issue Value Added Tax (VAT) invoices on purchase of goods and services.

According to the Commissioner-General of GRA, Rev. AmishaddaiOwusu-Amoah, the businesses were put before the Tax Courts for acting in contravention to Section 80 of the Revenue Administration Act 2016 (Act 915).

who needs to file fbar
Mr Owusu-Amoah (left) interacting with a participant

He explained that, the prosecution of tax defaulting businesses was one of the strategies adopted by the Authority to promote tax compliance and enforcement.

He was speaking on Friday during a meeting with editors of the various media organisations in Accra.

As at the end of September this year, Mr Owusu-Amoah said the GRA had collected GH¢51.6 billion as against a target of GH¢52 billion.

“We fell short of the target by GH¢466 million. The performance represents nominal growth rate of 29.0 per cent over same period compared to last year’s collection of 26 per cent. Domestic revenue grew nominally by 28.6 per cent while Customs revenue grew nominally by 29.8 per cent,” he added.

The Authority, he said, was implementing a number of tax policy initiatives including Taxpayers Portal, Electronic VAT Invoicing, Electronic Auction, and Electronic Tax Clearance Certificate to boost revenue generation this year.

He stated that Taxpayers portal was an online self-service system which allows taxpayers to file returns, initiate payments and access other tax related services such as Tax Clearance Certificates (TCCs), apply for tax reliefs, withholding tax exemptions, refunds and update of taxpayer information.

The Commissioner-General noted that the Electronic VAT invoicing was introduced to eliminate invoice cloning, carding and non-issuance of invoices and other irregularities which were affecting domestic tax performance.

“The E-VAT invoicing implementation will be done in phases starting October 1, 2022 and this will help the GRA to monitor the issuance of invoices by taxpayers by certifying all invoices issued for the purpose of accounting and filing of VAT returns,” he stated.

He said a new Excise Tax Stamp Authenticator had also been developed and would soon be used for scanning stamps on excisable products to ascertain whether the stamps were genuine or not. 

Starting October 15, MrOwusu-Amoah said the Electronic Auction platform would be piloted to deal with corruption associated with the auction of confiscated goods at the port and simplify the auction process.

He said the Electronic Tax Clearance Certificate was geared towards automating the process of obtaining Tax Clearance Certificates(TCCs) via the Taxpayers’ portal.

Additionally, the Authority, he noted, had instituted an Informant Award Scheme to award individuals, entities or organisations who offer confidential information to the GRA leading to the recovery of tax adding that an informant was recently paid GH¢130,000 for helping the Authority to recover tax.

“We encourage persons or individuals who have such information to call GRA. The information one provides will be treated with utmost confidentiality and where the information leads to the recovery of taxes, the informant will receive cash amounts in line with our Informant Policy,” the Commissioner-General stated.

Also, to improve the culture and professionalism of staff of GRA, he noted that a new Code of Ethics that defines the expected staff behaviour in line with GRA’s values of integrity had been published.

BY CLAUDE NYARKO ADAMS

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This news is brought to you by IWTA. Founded in 2015 and located on Avenue of the Americas, in the heart of New York City, International Wealth Tax Advisors provides highly personalized, secure and private global tax, GILTI, FATCA, Foreign Trusts consulting and accounting to many IWTAS.COM clients worldwide, including: Singapore, China, Mexico, Ecuador, Peru, Brazil, Argentina, Saudi Arabia, Pakistan, Afghanistan, South Africa, United Kingdom, France, Spain, Switzerland, Australia and New Zealand.

Heres Why The Bahamas Are An In-Demand Choice For Luxury U.S. Buyers

Heres Why The Bahamas Are An In-Demand Choice For Luxury U.S. Buyers

by | Oct 8, 2022 | 2022

Foreign tax credit

MAISON Bahamas, the leading luxury brokerage throughout the Bahamas, dives into the latest on the … [+] luxury real estate market.

MAISON Bahamas

From Nassau to Abaco Island, The Bahamas has various options for resort-style living, making it a popular choice for real estate investors and those seeking second-home ownership. Buyers from the United States are particularly appreciative of the country’s stable economy and its attractive tax advantages.

In the high-end of the market are properties like Villa Sul Mare, an oceanfront estate in the … [+] coveted Ocean Club Estates.

MAISON Bahamas

Getting to Nassau, the capital of The Bahamas, is convenient thanks to a dozen daily flights (currently scheduled) from Miami that take about an hour. American, Delta, and Jet Blue fly from JFK to Nassau in about 3.5 hours. For private flyers, options include Odyssey Aviation Nassau, a 24-hour full-service FBO with on-site customs and immigration services. Easy to access second and third homes in remote locations have become more appealing to today’s luxury buyers.

Luxury finishes abound at higher price-points. This $14.75-million villa features a minimalist … [+] design that provides spacious living with expansive patios.

MAISON Bahamas

I recently checked in with Ryan Knowles, founder and CEO of luxury brokerage MAISON Bahamas, to get the latest market news. Knowles is one of the leading realtors in the Bahamas.

Homes like this 9,000-square-foot mansion by the sea exude luxury and warmth thanks to imported … [+] touches such as Jerusalem stone floors, walls of Venetian plaster, exquisite chandeliers and custom millwork.

MAISON Bahamas

Describe your current market dynamics?

The real estate market in The Bahamas can be described in one word: “hot.” We had the busiest year on record in 2021, with throngs of international buyers hitting our shores in search of their piece of paradise. Demand continues to outstrip supply and we expect this trend to continue throughout the year.

Listed for $15.25 million, this Ocean Club Estates address includes exclusive access to The Ocean … [+] Club, a Four Seasons Resort, the Atlantis Resort & Casino (waterpark included) and their very own private Beach Club.

MAISON Bahamas

What changes have you seen so far in 2022?

Due to the sheer number of trades that occurred last year, there is simply less available inventory in the market for buyers to purchase. So, while demand remains incredibly high, deal volume has slowed a bit due to scarcity of product.

Called Villa La Plage, this contemporary jewel is perched atop a mile-long white sand beach in … [+] Nassau, Bahamas. Asking price: $7.95 million.

MAISON Bahamas

What potential changes do you forecast for the first half of 2022?

We anticipate two major adjustments, the first being that more buyers will opt for pre-construction or pre-completion offerings due to a lack of available inventory, and the second is that more and more sellers will come to the market, sensing an opportunity to take advantage of very favorable market conditions.

New construction in The Bahamas is coveted for its upscale designs incorporating high-end fixtures … [+] and amenities.

MAISON Bahamas

Do you see more sellers coming to market in your area. If so, how will that impact market conditions?

We’ve had an unprecedented surge of interest in recent months, and we don’t see that slowing down anytime soon. While we expect more sellers to enter the market, we believe that they will continue to be outnumbered by the number of buyers who want to get in. Everyone wants a piece of paradise and many of them are willing to pay full ask or more to get it!

MAISON Bahamas is an exclusive member of Forbes Global Properties, a consumer marketplace and membership network of elite brokerages selling the world’s most luxurious homes.

Follow me on Twitter or LinkedIn. Check out my website. 

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This news is brought to you by IWTA. Founded in 2015 and located on Avenue of the Americas, in the heart of New York City, International Wealth Tax Advisors provides highly personalized, secure and private global tax, GILTI, FATCA, Foreign Trusts consulting and accounting to many IWTAS.COM clients worldwide, including: Singapore, China, Mexico, Ecuador, Peru, Brazil, Argentina, Saudi Arabia, Pakistan, Afghanistan, South Africa, United Kingdom, France, Spain, Switzerland, Australia and New Zealand.

Queensland land tax: Media Watch’s false impression on Queensland land tax coverage

Queensland land tax: Media Watch’s false impression on Queensland land tax coverage

by | Oct 4, 2022 | 2022

Us trust private client advisor

Updated

Viewers of the ABC’s Media Watch on Monday night were given the impression that The Australian Financial Review’s coverage of the Queensland government’s now-abandoned land tax changes fell in with the interests of rich landlords and the property sector rather than with renters.

This rested on the left-wing Guardian Australia and left-wing academic economist (and former Financial Review columnist) John Quiggin.

us trust private client advisor

Media Watch didn’t properly explain the proposed tax change. 

Media Watch didn’t properly explain the proposed tax change, which would have taxed non-resident investors in Queensland property more heavily if they owned property in other parts of Australia.

It also ignored the prominent views to the contrary from one of Australia’s leading tax economists, Robert Breunig, director of the Tax and Transfer Policy Institute at the Australian National University.

In an op-ed column in the Financial Review posted on Sunday, Professor Breunig described this populist “eat the rich” tax as: “A tax that inclines property investors to take their money out, or not put their money into, Queensland.

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This news is brought to you by IWTA. Founded in 2015 and located on Avenue of the Americas, in the heart of New York City, International Wealth Tax Advisors provides highly personalized, secure and private global tax, GILTI, FATCA, Foreign Trusts consulting and accounting to many IWTAS.COM clients worldwide, including: Singapore, China, Mexico, Ecuador, Peru, Brazil, Argentina, Saudi Arabia, Pakistan, Afghanistan, South Africa, United Kingdom, France, Spain, Switzerland, Australia and New Zealand.

IRS New JSEIT Unit Will Use Crowdsourcing, Cooperative Intra-Agency Intelligence and Media Alerts to Quash Emerging Tax Fraud Schemes

IRS New JSEIT Unit Will Use Crowdsourcing, Cooperative Intra-Agency Intelligence and Media Alerts to Quash Emerging Tax Fraud Schemes

by | Oct 3, 2022 | Compliance, 2022

IRS New JSEIT Unit Will Use Crowdsourcing, Cooperative Intra-Agency Intelligence and Media Alerts to Quash Emerging Tax Fraud Schemes

Jack Brister s p 500

Jack Brister

Founder, International Wealth Tax Advisors

Jack Brister, Founder of International Wealth Tax Advisors, is a noted international tax expert, with over 25 years of experience. Jack specializes in U.S. tax planning and compliance for non-U.S. families with international wealth and asset protection structures.

Jack is a frequent featured speaker at numerous international financial conferences and has been named a Citywealth Top 100 U.S. Wealth Advisor.

Contact IWTA

To schedule an introductory phone conference with IWTA  founder Jack Brister simply click here. Email IWTA at bloginquiries@iwtas.com Or call the IWTA New York City office at 212-256-1142

IRS New JSEIT Unit Will Use Crowdsourcing, Cooperative Inter-Agency Intelligence and Media Alerts to Quash Emerging Tax Fraud Schemes

 

The Internal Revenue Service is upping its game with a newly formed team to identify and quickly address emerging tax compliance issues. 

Announced in June, the Joint Strategic Emerging Issues Team, or JSEIT, combines expertise from units across the agency, including Criminal Investigation, Tax Exempt/Government Entities, Large Business & International, and Small Business/ Self Employed.

JSEIT’s goal is to act before a tax scheme becomes a widespread issue. Acting as a conduit between taxpayers with compliance issues and the relevant IRS division, JSEIT hopes to provide early communication to prevent abusive fraud. Any transactions that have already been identified as abusive by the IRS will not be in focus. 

So how will JSEIT find these issues? According to the Agency, the group does not have a planned agenda, but instead will rely on communications from the public, from their peers at the agency and by combing through social media posts for potential issues. Their main goal is to quickly identify emerging issues and collaborate with all relevant teams to best address issues of noncompliance. An example would be a question on a scheme that an IRS official receives at a speaking engagement.

The Dirty Dozen

Every year the IRS compiles a list of 12 common scams that taxpayers may encounter, called the “Dirty Dozen.” As many of these schemes peak as returns during filing season, with the help of JSEIT, the Agency will prioritize those that are easily replicable, with the intention to alert the public and try to stop the issue before it becomes prevalent, such as those on the Dirty Dozen. 

Micro captive-insurance companies, (captive insurance companies operating with annual gross premiums up to 2.2 million) are an example of widespread tax abuse that the IRS is looking to shut down. The taxpayer/tax-paying entity forms a company to self insure; providing coverage in exchange for a tax-deductible premium. These captive insurance companies can then elect to be taxed only on the insurance premiums received. However, the company insured by the policies can still deduct the amount of premiums it pays as an ordinary business expense under IRC Sec. 162. Due to these attractive tax benefits as well as potential for tax evasion, the IRS identified these as “transactions of interest” in 2016, resulting in audits and Tax Court decisions that ruled for the IRS.

Other potentially abusive schemes listed on the 2022 IRS report included pandemic-related scams, monetized installment sales and use of charitable remainder annuity trusts.

JSEIT’s agenda is to promote voluntary compliance. Tax professionals and taxpayers should remain vigilant, as schemes can be found in emails, on social media platforms and through online advertisements. It is vital to keep abreast of these trends and changes and seek the advice of a trusted tax advisor with international expertise to help prevent unintended tax crimes and penalties.

 

Spain deliberates ‘digital nomad’ visa programme for remote workers

Spain deliberates ‘digital nomad’ visa programme for remote workers

by | Sep 27, 2022 | 2022

Cfc repatriation tax

cfc repatriation tax A representational image of a remote worker typing on a laptop. — Pexels/File
A representational image of a remote worker typing on a laptop. — Pexels/File

Spain is deliberating to issue ‘digital nomad’ visas providing non-EU citizens with the opportunity to work from anywhere in the country, while enjoying a low-cost lifestyle and tax breaks.

Visas would be issued to remote workers who work for companies outside Spain and those that generate at least 20% of their income from Spanish companies.

Details regarding the visa policy are yet to be worked out, as the law hasn’t been passed up till now; however, it is expected that initially the visa — fundamentally a resident permit — will be valid for a year and could be renewed for up to five years, subject to the applicant’s circumstances.

Even the applicant’s close relatives including their spouse or children will be eligible to join them, as reported by The Guardian.

In order to benefit from the policy, applicants must be from outside the European Economic Area and should be working remotely for at least a year. The applicant’s must have an employment contract or if they work freelance, they must prove evidence of regular work with a company outside Spain.

The applicants must also demonstrate that they will make enough earnings to be self-sufficient and have an address in Spain. However, it is not yet clear if they will have to be vetted through a criminal record check.

Instead of the standard 25% base rate, the visa holders will be taxed 15% for the first four years.

With the approval of the digital nomad visa programme, Spain will join 15 more European countries that offer similar versions of the visa and each country’s conditions vary.

A report published earlier this year stated that the average monthly income in Spain is €1,751 roughly over Rs400,000, 20% less than the average income in the EU which is €2,194.

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This news is brought to you by IWTA. Founded in 2015 and located on Avenue of the Americas, in the heart of New York City, International Wealth Tax Advisors provides highly personalized, secure and private global tax, GILTI, FATCA, Foreign Trusts consulting and accounting to many IWTAS.COM clients worldwide, including: Singapore, China, Mexico, Ecuador, Peru, Brazil, Argentina, Saudi Arabia, Pakistan, Afghanistan, South Africa, United Kingdom, France, Spain, Switzerland, Australia and New Zealand.

Open up, it’s the IRS. We’re here about the crypto tax you dodged

Open up, it’s the IRS. We’re here about the crypto tax you dodged

by | Sep 24, 2022 | 2022

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The IRS has been granted a court order to collect records from a bank the agency said will help it identify US taxpayers who failed to report taxable income from crypto trades. 

Uncle Sam yesterday said it’s specifically going after records from New York-based bank M.Y. Safra, which partnered with SFOX – a cryptocurrency prime broker – to offer the latter’s customers access to cash-deposit bank accounts. SFOX users could thus use funds at M.Y. Safra to buy and sell digital coins.

The IRS was granted a similar request against SFOX in August. Both organizations were served with “John Doe” summons, a tactic used by the IRS when it investigates wrongdoing without knowing the names of the accused taxpayers.

Basically, the IRS reckons people have profited from trading cryptocurrencies via SFOX and M.Y. Safra, and haven’t declared that income nor paid the required tax on it, and so the agency wants to chase those people down and strap them into the wallet-emptying ass-kicking machine.

“The John Doe summons directs M.Y. Safra to produce records that will enable the IRS to identify U.S. taxpayers who were customers of SFOX and who engaged in cryptocurrency transactions that may not have been properly reported on tax returns,” the agency said. 

According to the IRS, its probing into the world of cryptocurrencies has revealed “significant tax compliance deficiencies” across the industry, and that it “has strong reason to believe that many virtual currency transactions are not being properly reported on tax returns.” That said, there are many people who use cryptocoins for legit purposes, and pay due income taxes on it.

Per the IRS’s statement, SFOX has more than 175,000 registered users who have conducted more than $12 billion in transactions since 2015. The agency said it has identified “at least ten” – count ’em, ten – US taxpayers who have used SFOX but failed to report transactions. 

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With the data it gathers from M.Y. Safra, the IRS said it expects to be able to match the identities of SFOX users with Safra services “which the IRS will then be able to use in conjunction with other information to examine whether these users complied with the internal revenue laws.” 

Damian Williams, US Attorney for the Southern District of New York, where the summons was granted, said that cryptocurrency transactions aren’t exempt from tax liability. “The government is committed to using all of the tools at its disposal … to identify taxpayers who have understated their tax liabilities by not reporting cryptocurrency transactions, and to make sure that everyone pays their fair share,” Williams said. 

And another thing

Meanwhile, America’s Commodity Futures Trading Commission has filed and settled charges against blockchain outfit Ooki (formerly known as bZeroX) and its founders. 

The company and its pair of operators were collectively charged with illegal off-exchange asset trading, operating as unregistered futures commission merchants, and failing to adopt a customer identification program, as is required by the Bank Secrecy Act. 

The CFTC announced its settlement in the case along with the filing, stating that the respondents (the company and its two founders) will have to pay a $250,000 penalty, as well as promising to not to violate of the Commodity Exchange Act and CFTC regulations. ®

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This news is brought to you by IWTA. Founded in 2015 and located on Avenue of the Americas, in the heart of New York City, International Wealth Tax Advisors provides highly personalized, secure and private global tax, GILTI, FATCA, Foreign Trusts consulting and accounting to many IWTAS.COM clients worldwide, including: Singapore, China, Mexico, Ecuador, Peru, Brazil, Argentina, Saudi Arabia, Pakistan, Afghanistan, South Africa, United Kingdom, France, Spain, Switzerland, Australia and New Zealand.